CE marking and Brexit

[nigel jones 5Participant @nigeljones5]

It has just dawned on me that once we are out of the EU the requirement to have CE registration & certification will no longer stand for items built and placed exclusively on the UK market. I wonder what the SF will put in place of this for commercial boilers made within the UK – more red tape?

[nigel jones 5Participant @nigeljones5]

[Bob Brown 1Participant @bobbrown1]

Back to the old kite mark or may be retain the CE standard, one of the many things that will need to be sorted as the UK legislation is extracted from the EU. I wonder if anyone has thought of the costs as the lawyers trawl through it all.

[nigel jones 5Participant @nigeljones5]

I bet the lawyers have !!

[KWILParticipant @kwil]

CE does not mean anything other than that the Maker has tested the items to the required standard.

So a simple statement can replace that. along with SF paperwork, no need for further complications. A private maker gets the Club Inspector to certify, a commercial maker (Preferably a Member of the Copper Boiler Maker's Association) merely states the same.

Good bye and good riddance to CE.

[MWParticipant @mw27036]

On a technicality we are still members of the E.U until the negotiations are settled, presumably in the culmination of an amnesty for those foreign citizens who are already here and those Britons abroad, this would need to be limited though if done properly, to make sure the treaty can't be abused in practice.

It could be decided that many of the laws initiated under the E.U would still be adhered to and a formal legal arrangement would need to be setup in order to make sure new products still comply to the C.E standard.

This would be completely necessary because if we were to ignore the legislature and simply carry on as normal, there is no formal framework on which to base our own quality assessments in the future.

I imagine that the full disentanglement will take around 10 years. We will need to decide on everything we wish to keep and enact that, and discard everything we don't want.

So as you can see, the question is never "will we" have a CE mark, but more like "how and what form will it take".

The UK has on the most part been a very negotiable country and it's more a question of how open the other parties are to discussion rather than the other way around.

Michael W

[Bob Brown 1Participant @bobbrown1]

If manufacturers want to supply into the EU once we are out then goods supplied will need to meet the EU standards (CE mark) just as they need to meet US standards to supply goods there or any other countries standards.

[S.D.L.Participant @s-d-l]

Posted by KWIL on 01/08/2016 16:16:29:

CE does not mean anything other than that the Maker has tested the items to the required standard.

So a simple statement can replace that. along with SF paperwork, no need for further complications. A private maker gets the Club Inspector to certify, a commercial maker (Preferably a Member of the Copper Boiler Maker's Association) merely states the same.

Good bye and good riddance to CE.

That is not the case with steel boilers as in traction engines, as if sold commercially a notified body normally checks the design, the welder qualifcation records and the final pressure test, along with possibly intermediate inspections.

Steve

[S.D.L.Participant @s-d-l]

Posted by fizzy on 01/08/2016 15:39:30:

It has just dawned on me that once we are out of the EU the requirement to have CE registration & certification will no longer stand for items built and placed exclusively on the UK market. I wonder what the SF will put in place of this for commercial boilers made within the UK – more red tape?

Could be a lot more from government. The level of expertise in the civil service for these sort of things has been reduced so there will be a period of hiring, then the laws passed under EU directives will have to be written into UK law with more chances of extra regulation or accept the EU rules under PED and have no say in there modification.

Remember the SF, NA and others got the model engineering exemptions for home built boilers.

Steve

[Sam Longley 1Participant @samlongley1]

A sizeable proportion of EU standards throughout industry have been derived from the British ISO & BSS standards. The British Standards Institute have enabled themselves to be self financing to a large extent by the sale of these standards to the EU. They also offered advice & have been at the forefront  in formation of new standards. So in a lot of cases the changes would not actually be that difficult.

However, I am not sure how the standards applicable to the model engineering hobby would alter. Obviously other countries had input such as the French Agrement certification scheme which was combined with things such as the BBA etc & these may be bread & butter for the lawyers

 

Edited By Sam Longley 1 on 01/08/2016 18:52:25

[Neil WyattModerator @neilwyatt]

Posted by S.D.L. on 01/08/2016 18:40:34:

Posted by fizzy on 01/08/2016 15:39:30:

It has just dawned on me that once we are out of the EU the requirement to have CE registration & certification will no longer stand for items built and placed exclusively on the UK market. I wonder what the SF will put in place of this for commercial boilers made within the UK – more red tape?

Could be a lot more from government. The level of expertise in the civil service for these sort of things has been reduced so there will be a period of hiring, then the laws passed under EU directives will have to be written into UK law with more chances of extra regulation or accept the EU rules under PED and have no say in there modification.

Other way round, the EU directives are all now UK law so anything that changes will have to be repealed and replaced, an exercise which will be resisted by anyone who wants to sell into Europe, as they won't want two sets of regulations.

I think the ONE change we will all welcome is that it will be possible to have 'Buy British' campaigns again!

Neil

[Michael GilliganParticipant @michaelgilligan61133]

Posted by Neil Wyatt on 01/08/2016 18:59:37:

I think the ONE change we will all welcome is that it will be possible to have 'Buy British' campaigns again!

.

Sad though, that so much of British "manufacturing" involves the assembly of imported parts and slapping a sticker on.

MichaelG.

[Old SchoolParticipant @oldschool]

Most standards used in the EU are Euro Norms each country publishes it own standard with a national forward for us they are BS EN and for France they are NF EN etc, so in reality BSI sells quite small quantities of standards. Most of the experts BSI uses come from industry and a large part of the costs of these experts is paid by industry. For us to supply product into Europe we will still need to find some way of CE marking a lot of it is done by manufacturers who are allowed to self certify under a scheme run by BSI. It going to take some sorting out.

[MWParticipant @mw27036]

Posted by Michael Gilligan on 01/08/2016 19:09:53:

Posted by Neil Wyatt on 01/08/2016 18:59:37:

I think the ONE change we will all welcome is that it will be possible to have 'Buy British' campaigns again!

.

Sad though, that so much of British "manufacturing" involves the assembly of imported parts and slapping a sticker on.

MichaelG.

I wouldn't have such nonsense under my watch. When i say made, i mean made in Britain!

Michael W

[duncan webster 1Participant @duncanwebster1]

Posted by KWIL on 01/08/2016 16:16:29:

CE does not mean anything other than that the Maker has tested the items to the required standard.

So a simple statement can replace that. along with SF paperwork, no need for further complications. A private maker gets the Club Inspector to certify, a commercial maker (Preferably a Member of the Copper Boiler Maker's Association) merely states the same.

Good bye and good riddance to CE.

Not the case. CE mark confirms that the item meets all relevant standards, in this case the Pressure Systems Directive. I've read it, which is more than a lot of the people who pontificate on this forum have, and it is a very sensible document. All a pressure test confirms is that using cold water the boiler is capable of holding pressure once. I'd like to know before parting with a lot of money that for instance the correct materials have been used. Why do we get so aereated? Anyone who sets up as a boiler maker and can't meet the standards should not be in business. Producing the paperwork to confirm compliance is a very small part of the cost of such a simple thing as a copper boiler. If our boilermakers want to trade with the EU they will have to continue to abide by the standards, and I can't image our government saying "OK lads, you can sell anything you like, no standards, no paperwork"

[SillyOldDufferModerator @sillyoldduffer]

Posted by fizzy on 01/08/2016 15:39:30:

It has just dawned on me that once we are out of the EU the requirement to have CE registration & certification will no longer stand for items built and placed exclusively on the UK market. I wonder what the SF will put in place of this for commercial boilers made within the UK – more red tape?

A even more awkward question is "When will the UK really be out of the EU?"

Nothing happens until Article 50 is invoked by us and we don't appear to be ready to do that yet. The Brexit campaign didn't cover any of the details, there isn't a single vision, there are many risks, and cost/benefit of the various components will be a problem.

After Article 50 is triggered, we enter into a period of negotiation that ends with agreed arrangements for managing the separation together with a framework describing our future relationship with the Union. The negotiation can take up to 2 years throughout which time our membership obligations remain in force. Once the negotiation is complete, the EU will need to obtain the consent of the European Parliament and a qualified majority in the European Council. On the UK side, it's less clear how the decision will be confirmed, but my guess is an Act of Parliament will be needed. It could easily take 4 or 5 years to sort that lot out.

But it's only then that the real work starts. I have no idea how long it will take to replace 45 years worth of legislation and EU aligned practice, or how long it will take the economy to take advantage of the new rules, or how long it will take to conclude new trade deals etc. It's rather likely that the Article 50 negotiation will leave a lot in place, including free movement of people, and that it will take a decade or two to sort out the rest.

Interesting times ahead. I intend to spend more time with my lathe!

Dave

[MuzzerParticipant @muzzer]

Things will still be built and tested to pretty much the same standards. Even if the CE mark may not be mandated it will still be applied even if the sticker itself isn't. All it will mean is that we have not only to ensure compliance with the EU but also a whole new set of regulations that will apply only to the UK. In another context we might call that "more red tape" for businesses to deal with but it's certainly nothing to get smug about and provides no competitive advantage – quite the opposite.

As pointed out above, the regulations are pretty much harmonised across the Western world so the requirements really aren't about to relax, although the way they are certified will be more onerous.

[Mark CParticipant @markc]

The latest farcical idea that building a production line from ce marked equipment then requires its own ce mark for the whole line might just get dropped…..

Mark

[MuzzerParticipant @muzzer]

Where do you read drivel like that? You have to design systems like this to regulations like IEC 61508 etc anyway and you have to declare it somehow, whether by CE marking (or UL, CSA etc etc). You would not be able to sell, insure or operate a facility that uses it otherwise.

[Bob Brown 1Participant @bobbrown1]

Some standards are still a BS standard like electrical installations e.g. British Standard BS 7671.

[Enough!Participant @enough]

Posted by Mark C on 01/08/2016 21:57:03:

The latest farcical idea that building a production line from ce marked equipment then requires its own ce mark for the whole line might just get dropped…..

That doesn't sound any different, in principle, to what I used to go through here (Canada) with CSA/UL approvals. Individual components in a product would require CSA/UL approval where appropriate but the end-product would still require CSA/UL approval.

Even if a component part is approved in itself, it could still be mis-applied when built into a product.

[Mark CParticipant @markc]

Try this concept then – buy a bag filling machine a hopper and a weigh station, all ce approved. join them together in a "production line" and the whole thing then requires approval. Why would I need to approve my own line built from approved equipment?

I understand the idea about components making up a larger bit of kit but this is a production line and for your own use…… you still think it is drivel? Its mad. It is the latest proposals being floated regarding automation etc.

Mark

[Sam Longley 1Participant @samlongley1]

Posted by Old School on 01/08/2016 19:12:25:

Most standards used in the EU are Euro Norms each country publishes it own standard with a national forward for us they are BS EN and for France they are NF EN etc, so in reality BSI sells quite small quantities of standards. Most of the experts BSI uses come from industry and a large part of the costs of these experts is paid by industry. For us to supply product into Europe we will still need to find some way of CE marking a lot of it is done by manufacturers who are allowed to self certify under a scheme run by BSI. It going to take some sorting out.

I hope that you are not putting the BSI down- ( a British disease I believe )

It is a world leader in advising on standards in industry,

[Neil WyattModerator @neilwyatt]

Posted by Mark C on 01/08/2016 22:37:46:

Try this concept then – buy a bag filling machine a hopper and a weigh station, all ce approved. join them together in a "production line" and the whole thing then requires approval. Why would I need to approve my own line built from approved equipment?

It's not hard to imagine ways of combining two safe machines to make a dangerous situation. How is the law to know in advance which combinations are safe and which aren't?

Surely your 'simple system' should be simple to self-certify? I would have thought the manufacturers would be able to give you all the required data so you can just add your own risk assessment and top and tail it?

For us to supply product into Europe we will still need to find some way of CE marking a lot of it is done by manufacturers who are allowed to self certify under a scheme run by BSI. It going to take some sorting out.

The systems are all in place already. What has to change?

Neil

[David JuppParticipant @davidjupp51506]

Notified Bodies are appointed by Member States of the EU – so depending upon quite what Brexit ends up meaning, it is possible that the UK may not be able to appoint Notified Bodies. I think nobody has a real clue about which way this will end up. I am aware of one UK Notified body that has taken the precaution of registering a company in another EU country, so that if necessary it will be able to provide services within the UK under the umbrella of that new company.

UK manufacturers can already choose to use NBs from other EU states if they so wish – some have offices in the UK.

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